Tax Planning, Fees

AbbVie's Tax Triumph: Breaking Free from Capital Loss Limitations

Holland & Knight LLP on 6/30/2025

In a significant win for taxpayers, the U.S. Tax Court recently ruled in AbbVie Inc. v. Commissioner, Docket No. 2597-23, that a $1.6 billion "Break Fee" paid by AbbVie qualifies as an ordinary and necessary business expense...more

DL Rilancio e Credito d'imposta per i canoni di locazione degli immobili a uso non abitativo e affitto d'azienda

Orrick, Herrington & Sutcliffe LLP on 5/27/2020

Lo scorso 19 maggio 2020 è stato pubblicato in Gazzetta Ufficiale ed è entrato in vigore il Decreto Legge 19 maggio 2020, n. 34, recante “Misure urgenti in materia di salute, sostegno al lavoro e all’economia, nonché di...more

You’ve Got Another PCORI Fee Coming!: Congress revives the PCORI fee and filing obligations

Holland & Hart - The Benefits Dial on 3/5/2020

In the wee hours of December 2019, Congress revived the PCORI fee and filing obligations of employer sponsors of self-insured group health plans. In accordance with the requirements of the Affordable Care Act, employer...more

Department of Revenue Issues Pennsylvania Sales and Use Tax Letter Ruling No. SUT-20-001 – Regarding Taxation of Membership Fee

McNees Wallace & Nurick LLC on 2/5/2020

On January 31, 2020, the Pennsylvania Department of Revenue (“Revenue”) issued Letter Ruling No. SUT-20-001, which concluded that the taxability of a membership fee in a professional association depends upon what a member...more

Minnesota Revenue Department Issues Notice on Surplus Lines Insurance Taxation

Stinson LLP on 1/22/2020

The Minnesota Department of Revenue recently published a revenue notice to clarify how brokers of surplus lines insurance policies should calculate the total amount of insurance premiums that are subject to taxation,...more

Transaction Cost Deduction Denied - Tax Court Found Finder's Fee Paid By Target Was Not Paid For Benefit Of Target - Tax Update:...

Troutman Pepper Locke on 1/15/2020

Plano Molding Co. (target), a manufacturer of plastics, was acquired by Plano Holding, an affiliate of the Ontario Teachers’ Pension Plan Board (buyer), from Tinicum Capital Partners (seller). ...more

Ding, Dong, the PCORI Fee is Dead!

Burr & Forman on 7/8/2019

Insurance carriers and employer sponsors of health plans were not exactly thrilled with the passage of the Affordable Care Act in 2010. You might say, the Affordable Care Act was viewed as the “wicked witch.” Although the...more

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